Punzalan v. Ferriols
REITERATIONFacts
The Antecedents: Andres Punzalan's horse was shot pursuant to a provincial ordinance enacted by the Provincial Board of Batangas. The ordinance was adopted under the authority of Act No. 83, as amended by Act No. 133, to prevent the spread of infectious animal diseases. The horse was declared to be suffering from surra, a contagious and incurable disease, by a veterinary surgeon. Procedural History: The court below rendered judgment against the Province of Batangas for P120, the alleged value of the horse, finding in favor of the plaintiff, Andres Punzalan. The Petition: The defendants, Sisenando Ferriols (municipal president of Batangas) and the Provincial Board of Batangas, appealed the decision of the lower court.
Issue(s)
Whether the provincial ordinance authorizing the destruction of diseased animals is invalid for failing to provide compensation to the owner. Whether the authority to provide by ordinance for the destruction of diseased animals is included within the powers granted to provincial boards under Section 13(k) of Act No. 83, as amended by Act No. 133.
Ruling
The judgment of the court below is reversed, and the complaint is dismissed. The Province of Batangas is not liable for the value of the horse.
Ratio Decidendi
On the issue of compensation for the destruction of diseased animals: The Court held that the provisions of the Philippine Bill of Rights, specifically those concerning due process and equal protection, and the right to just compensation in eminent domain, were not intended to deny the Philippine government the right to exercise its sovereign police power in the promotion of the general welfare and public interest. The quarantine, isolation, and slaughter of cattle suffering from infectious or contagious diseases are universally recognized as proper exercises of this power when public necessity demands such interference with or destruction of private property, provided the means adopted are reasonably necessary. The ordinance in question was deemed eminently fair and just, guarding the owner from reckless action and protecting property rights within the limits of necessity. On the issue of the provincial board's authority to enact the ordinance: The Court found that Section 13(k) of Act No. 83, as amended by Act No. 133, which grants provincial boards the power to adopt regulations for the suppression of agricultural pests like cattle diseases, clearly confers upon them the same power to adopt necessary regulations as was vested in the Philippine Commission itself. There were no limitations on this grant of power, and the provincial boards have the perfect right, under the authority conferred, to make regulations for the slaughter of diseased animals when necessary for the effective suppression of disease among cattle, consistent with the exercise of the sovereign police power for the promotion of the general welfare and public interest.
Main Doctrine
Provincial boards possess the power to adopt regulations for the suppression of cattle diseases, including the slaughter of infected animals, as a valid exercise of the sovereign police power for the promotion of the general welfare and public interest, provided such measures are reasonably necessary and do not violate due process or the right to just compensation when private property is taken for public use.